Holding

The High Court erred in ordering narco‑analysis of all accused; a voluntary narco‑analysis report cannot alone support a conviction, and an accused has no indefeasible right to such a test, only a conditional right subject to safeguards.

Summary

The appellant, Amlesh Kumar, was charged with multiple offences including dowry harassment and murder after his wife went missing. While seeking regular bail, the High Court of Patna accepted the Sub‑Divisional Police Officer's proposal to conduct narco‑analysis tests on all accused and witnesses. The Supreme Court held that such an order violated the constitutional protections under Articles 20(3) and 21 as articulated in Selvi v. State of Karnataka. It further ruled that a report of a voluntary narco‑analysis cannot, by itself, constitute the sole basis for a conviction absent corroborative evidence under Section 27 of the Evidence Act. The Court clarified that an accused may voluntarily undergo narco‑analysis only at the appropriate stage of trial and only after the court is satisfied of free consent and safeguards, but there is no indefeasible right to demand the test. Consequently, the High Court's order was set aside and the appellant's appeal was allowed.

Issues considered

Whether the High Court could accept a submission to conduct narco‑analysis tests on all accused persons during the investigation.
Whether a report of a voluntary narco‑analysis test can form the sole basis of conviction in the absence of other evidence.
Whether an accused has an indefeasible right to voluntarily undergo a narco‑analysis test.

Legislation cited

Code of Criminal Procedure, 1973s. 439
Evidence Act, 1872s. 27

Headnote

Issue for Consideration Whether in the attending facts and circumstances, the High Court could have accepted a submission of the Sub-Divisional Police Officer, to conduct narco-analysis test of all the accused persons (including the appellant) and other witnesses, during the investigation; whether form the sole basis of conviction in the absence of other evidence on record; whether an accused can voluntarily seek a narco-analysis test, as a matter of an indefeasible right. Headnotes† Constitution of India – Art.20(3) and Art.21 – Code of Criminal Procedure, 1973 –

Subjects

Narco-analysis testForced or involuntary narco-analysis testRegular bailRight against self-incriminationRight to privacyIndefeasible rightArticle 20(3) of the Constitution of India

Judgment

[2025] 7 S.C.R. 394 : 2025 INSC 810

Amlesh Kumar
v.
The State of Bihar
(Criminal Appeal No. 2901 of 2025)
09 June 2025
[Sanjay Karol* and Prasanna B. Varale, JJ.]

Issue for Consideration
Whether in the attending facts and circumstances, the High
Court could have accepted a submission of the Sub-Divisional
Police Officer, to conduct narco-analysis test of all the accused
persons (including the appellant) and other witnesses, during
the investigation; whether a report of a voluntary narco-analysis
test can form the sole basis of conviction in the absence of other
evidence on record; whether an accused can voluntarily seek a
narco-analysis test, as a matter of an indefeasible right.

Headnotes†
Constitution of India – Art.20(3) and Art.21 – Code of Criminal
Procedure, 1973 – s.439 – The High Court accepted the
submission of the Sub-Divisional Police Officer, Mahua, that
she would conduct narco-analysis test of all the accused
persons (including the appellant herein) and other witnesses,
during the investigation – Correctness:
Held: There was no reason for the High Court to accept a
submission by the Investigating Officer, stating that they will
conduct a narco-analysis test of all the accused persons – Such
a submission and its acceptance, is in direct contravention to the
judgment of this Court in Selvi, being hit by the protections u/
Arts.20(3) and 21 of the Constitution – Moreover, it is settled law
that while entertaining an application for grant of bail, the Court
has to take into consideration the allegations against the accused;
period of custody undergone; nature of evidence and the crime
in question; likelihood of influencing witnesses and other such
relevant grounds – It does not involve entering into a roving enquiry
or accepting the use of involuntary investigative techniques –
Therefore, the High Court has erred in accepting a submission
to carry out a narco-analysis test of all accused persons by the
Investigating Officer. [Paras 10, 11, 13]
* Author
[2025] 7 S.C.R. 395

Amlesh Kumar v. The State of Bihar

Evidence, 1872 – s.27 – Whether a report of a voluntary
narco-analysis test can form the sole basis of conviction in
the absence of other evidence on record:
Held: This Court in Selvi had considered voluntary narco-analysis
tests and opined that the reports thereof cannot be admitted directly
into evidence – Information that is discovered, as a consequence
thereof, can be admitted with the aid of s.27 of the Evidence Act,
1872 – It is settled that in the absence of supporting evidence, a
conviction cannot be based solely on such information – Therefore,
a report of a voluntary narco analysis test with adequate safeguards
as well in place, or information found as a result thereof, cannot form
the sole basis of conviction of an accused person. [Paras 14, 15, 16]

Evidence – Voluntary narco-analysis test – Whether an accused
can voluntarily seek a narco analysis test, as a matter of an
indefeasible right:
Held: The accused has a right to voluntarily undergo a narco-
analysis test at an appropriate stage – The appropriate stage for
such a test to be conducted is when the accused is exercising his
right to lead evidence in a trial – However, there is no indefeasible
right with the accused to undergo a narco-analysis test, for upon
receipt of such an application the concerned Court, must consider
the totality of circumstances surrounding the matter, such as free
consent, appropriate safeguards etc., authorizing a person to
undergo a voluntary narco-analysis test. [Para 21]

Case Law Cited
Selvi and Ors. v. State of Karnataka [2010] 5 SCR 381 : (2010)
7 SCC 263; Sangitaben Shaileshbhai Datana v. State of Gujarat
(2019) 14 SCC 522; Vinobhai v. State of Kerela, 2025 SCC Online
SC 178; Manoj Kumar Soni v. State of M.P., 2023 SCC OnLine
SC 984 – relied on.
Rajesh Talwar v. CBI, 2013 SCC Online All 5533; Dominic Luis v.
State, 2014 SCC Online Bom 452; Mohd. Samir v. State, 2017
SCC Online Bom 19; Ashwini Kumar Upadhyay v. Union of India,
2023 SCC Online Del 3816; Louis v. State of Kerala, 2021 SCC
Online Ker 4519; State of Gujarat v. Sanjay Kumar Kanchanlal
Desai, 2014 SCC Online Guj 6150; Navjeet Kaur v. State of
Punjab, 2015 SCC Online P&H 15351 – referred to.
396 [2025] 7 S.C.R.

Supreme Court Reports

Books and Periodicals Cited
B R Sharma, Forensic Science in Criminal Investigation & Trials,
Sixth Edition, 2020 – Paragraph 32.1.1

List of Acts
Constitution of India; Code of Criminal Procedure, 1973; Evidence,
1872.

List of Keywords
Narco-analysis test; Forced or involuntary narco-analysis test;
Regular bail; Right against self-incrimination; Right to privacy;
Indefeasible right; Article 20(3) of the Constitution of India.

Case Arising From
CRIMINAL APPELLATE JURISDICTION: Criminal Appeal No.
2901 of 2025
From the Judgment and Order dated 09.11.2023 of the High Court
of Judicature at Patna in CRLM No. 71293 of 2023

Appearances for Parties
Gaurav Agrawal, Sr. Adv./Amicus Curiae, Manan Garg.
Advs. for the Appellant:
Mithilesh Kumar Singh, Ashutosh Kumar Singh, Mrs. Manju Singh,
Aditya Durgvanshi, Saumitra Singh, Apurva Pandey.
Advs. for the Respondent:
Anshul Narayan, Prem Prakash.

Judgment / Order of the Supreme Court

Judgment

Sanjay Karol, J.

Leave Granted.
2. The present Appeal arises from the impugned Order dated 9th
November 2023 passed in Criminal Miscellaneous No.71293 of
2023 by the High Court of Judicature at Patna, whereby the Court
[2025] 7 S.C.R. 397

Amlesh Kumar v. The State of Bihar

accepted the submission of the Sub-Divisional Police Officer, Mahua,
that she would conduct narco-analysis test of all the accused persons
(including the Appellant herein) and other witnesses, during the
investigation.
3. Aggrieved thereof, the Appellant is before us. The significant ground
of challenge taken is that the acceptance of such a submission by
the High Court is in direct contravention of the exposition of law
laid down by this Court in Selvi and Ors. v. State of Karnataka1,
wherein it was observed that forceful subjection of an individual to
techniques, such as the narco-analysis test, violates personal liberty
enshrined under Article 21 of the Constitution of India.
4. The brief facts giving rise to the Appeal at hand are as follows:
4.1. On 24th August 2022, FIR No.545 of 2022 was registered at
P.S. Mahua under Sections 341, 342, 323, 363, 364, 498(A),
504, 506 and 34 of the Indian Penal Code, 18602, against
the Appellant (husband) and his family. It was stated by the
complainant therein that her sister got married to the Appellant
on 11th December 2020, and thereafter, the accused persons
had been making repeated demands for dowry and beating her.
On 22nd August 2022, she received a call from the Appellant,
informing that her sister had run away from the matrimonial
home. Despite searching, she is unable to locate her sister
and suspects foul play by the accused persons (including the
Appellant).
4.2. The case of the Appellant is that on 21st August 2022, while en
route to Ayodhya, his wife got off the bus at Baabali Chawk for
nature’s call but never returned. He filed a complaint before P.S.
Jahangir Ganj, recorded as GD No. 038, on 28th August 2022.
4.3. The admitted position is that the missing person (wife) has
not been found to date. The mother, father and brothers of
the Appellant have been granted bail by the High Court of
Judicature at Patna.
4.4. The Appellant’s prayer for regular bail came to be rejected vide
Order dated 1st August 2023 passed by the Sessions Judge,

1 (2010) 7 SCC 263.
2 Hereinafter ‘IPC’.
398 [2025] 7 S.C.R.

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Vaishali at Hajipur in B.P.No.1141 of 2023. The Court was not
inclined to grant bail on the basis of the allegations made in the
FIR, as well as the confessional statements of the co-accused,
who stated that they had thrown the missing person in the river
Saryu on the intervening night of the 21st and 22nd August 2022.
4.5. Dissatisfied with the Order of the Sessions Judge, the Appellant
approached the High Court of Judicature at Patna for grant of a
regular bail vide Crl. Misc. No.71293 of 2023. Vide the impugned
interim Order, the High Court accepted the submission of the
Sub-Divisional Police Officer, Mahua, that she will conduct a
narco-analysis test of all the accused persons and posted the
case for hearing on 12th July 2024. The relevant portion thereof
is extracted below, for ready reference :
“2. Pursuant to the order dated 07.11.2023, the
SubDivisional Police Officer, Mahua and the S.H.O.
Mahua are present in the court.
3. The S.D.P.O. Mahua, assures this court that she
will take further steps in the investigation to find out
details about the missing woman and for that she has
further submitted that she will get narco test of all the
accused persons and other witnesses, if required in
the investigation.
4. List this case on 12.07.2024.
5. On the next date of hearing, the investigation report
shall be produced by the learned APP.”
(Emphasis supplied)

4.6. Aggrieved thereof, the Appellant has preferred the present
Appeal before this Court.
5. We have heard the learned counsel for the Appellant and the learned
Addl. Standing Counsel on behalf of the Respondent State. After
hearing the parties in part, vide Order dated 22nd April 2025, this
Court appointed Mr. Gaurav Agrawal, Senior Advocate, as an Amicus
Curiae to assist the Court, given the issues involved. We have heard
the learned Amicus Curiae and the learned counsel for the parties
as also perused the written submissions filed.
[2025] 7 S.C.R. 399

Amlesh Kumar v. The State of Bihar

6. Consequently, the issues which arise for consideration of this Court
are :
i. Firstly, whether in the attending facts and circumstances, the
High Court could have accepted such a submission.
ii. Secondly, whether a report of a voluntary narco-analysis test
can form the sole basis of conviction in the absence of other
evidence on record.
iii. Lastly, whether an accused can voluntarily seek a narco-analysis
test, as a matter of an indefeasible right.
7. For the purposes of clarity, a narco-analysis test is an interrogation
method whereby a suspect of a crime is injected with a psychoactive
drug under controlled conditions to suppress their reasoning power
or the ability to determine what is good/bad for themselves.3 As
submitted by the learned Amicus Curiae, the drug used for this test is
sodium pentothal, which is also used in higher dosages for inducing
general anesthesia in surgeries.
8. However, conducting such tests on persons accused of committing a
crime raises serious questions, vis-à-vis, the constitutional protection
granted from compulsion to become a witness against oneself under
Article 20(3). The constitutional validity of this test, along with similar
tests like the polygraph test, came to be challenged before this Court
in Selvi (supra). After an elaborate discussion, this Court (three-
Judge Bench) held involuntary administration of this test to be hit
by Articles 20(3) and 21 of the Constitution. The following principles
came to be expounded:
8.1. Articles 20 and 21 of the Constitution are non-derogable
and sacrosanct rights to which the judiciary cannot carve out
exceptions;
8.2. Involuntary administration of narco-analysis and similar tests is
in contravention of the protection given by Article 20(3) of the
Constitution, i.e. the right against self-incrimination;
8.3. The results of such involuntary tests cannot be considered as
‘material evidence’ in the eyes of the law;

3 B R Sharma, Forensic Science in Criminal Investigation & Trials, Sixth Edition, 2020 – Paragraph 32.1.1.
400 [2025] 7 S.C.R.

Supreme Court Reports

8.4. Conducting such tests in the absence of consent violates
‘substantive due process’ – which is an essential element
required for restraining one’s personal liberty. Permitting such
tests may lead to a disproportionate exercise of police powers;
8.5. The boundaries of privacy of a person are also breached when
these tests are conducted without consent; and
8.6. For voluntary tests, it must be ensured that appropriate
safeguards are in place. Moreover, the results of the same
cannot be admitted directly as evidence. Pertinently, any fact
or information that is discovered subsequent thereto, with the
help of the information supplied in the result, can be admitted
into evidence with the aid of Section 27 of the Indian Evidence
Act 1872.
9. From the above exposition of law, it is clear that under no
circumstances, is an involuntary or forced narco-analysis test
permissible under law. Consequently, a report of such involuntary
test or information that is discovered subsequently is also not per
se admissible as evidence in criminal or other proceedings.
10. Adverting to the facts at hand, we cannot find a reason in the High
Court accepting a submission by the Investigating Officer, stating that
they will conduct a narco-analysis test of all the accused persons.
Such a submission and its acceptance, is in direct contravention to
the judgment of this Court in Selvi (supra), being hit by the protections
under Articles 20(3) and 21 of the Constitution.
11. Moreover, we fail to understand how such an endeavour was accepted
by the High Court when adjudicating an application for regular bail
under Section 439 of the Code of Criminal Procedure, 1973. It is
settled law that while entertaining an application for grant of bail,
the Court has to take into consideration the allegations against the
accused; period of custody undergone; nature of evidence and the
crime in question; likelihood of influencing witnesses and other such
relevant grounds. It does not involve entering into a roving enquiry or
accepting the use of involuntary investigative techniques. In similar
circumstances, where the High Court had ordered lie detector,
brain mapping and narco-analysis tests, this Court in Sangitaben
Shaileshbhai Datana v. State of Gujarat4, observed :

4 (2019) 14 SCC 522.
[2025] 7 S.C.R. 401

Amlesh Kumar v. The State of Bihar

“6. Having heard the counsel for the parties, it is
surprising to note the present approach adopted by the
High Court while considering the bail application. The
High Court ordering the abovementioned tests is not
only in contravention to the first principles of criminal law
jurisprudence but also violates statutory requirements.
While adjudicating a bail application, Section 439 of the
Code of Criminal Procedure, 1973 is the guiding principle
wherein the court takes into consideration, inter alia, the
gravity of the crime, the character of the evidence, position
and status of the accused with reference to the victim and
witnesses, the likelihood of the accused fleeing from justice
and repeating the offence, the possibility of his tampering
with the witnesses and obstructing the course of justice
and such other grounds. Each criminal case presents its
own peculiar factual matrix, and therefore, certain grounds
peculiar to a particular case may have to be taken into
account by the court. However, the court has to only
opine as to whether there is a prima facie case against
the accused. The court must not undertake meticulous
examination of the evidence collected by the police, or
rather order specific tests as done in the present case.
7. In the instant case, by ordering the abovementioned tests
and venturing into the reports of the same with meticulous
details, the High Court has converted the adjudication of a
bail matter to that of a mini trial indeed. This assumption of
function of a trial court by the High Court is deprecated.”
(Emphasis supplied)

12. We are not inclined to accept the submission of the Respondent-
State that since modern investigative techniques are the need of
the hour, the High Court was correct in accepting the submission
that narco-analysis test of all accused persons will be conducted.
While the need for modern investigative techniques may be true,
such investigative techniques cannot be conducted at the cost of
constitutional guarantees under Articles 20(3) and 21.
13. Therefore, the first question framed is answered in the negative.
The High Court has erred in accepting a submission to carry out a
narco-analysis test of all accused persons by the Investigating Officer.
402 [2025] 7 S.C.R.

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14. In the course of proceedings, the issue of undergoing a narco-analysis
test voluntarily came to be raised, which brings us to the second
question framed. As discussed above, this Court in Selvi (supra)
had considered voluntary narco-analysis tests and opined that the
reports thereof cannot be admitted directly into evidence. Information
that is discovered, as a consequence thereof, can be admitted with
the aid of Section 27 of the Indian Evidence Act, 1872.
15. The evidentiary value of information received through the aid of
Section 27 is no longer res integra. This Court in Vinobhai v. State
of Kerela5, while placing reliance on Manoj Kumar Soni v. State of
M.P.6 held that in the absence of supporting evidence, a conviction
cannot be based solely on such information. It was observed:
“8. ….. The law relating to the evidentiary value of recovery
made under Section 27 of the Indian Evidence Act, 1872
is settled by this Court in the case of Manoj Kumar Soni v.
State of M.P.. Paragraph 22 of the said decision reads
thus:—
“22. A doubt looms : can disclosure statements per
se, unaccompanied by any supporting evidence,
be deemed adequate to secure a conviction?
We find it implausible. Although disclosure
statements hold significance as a contributing
factor in unriddling a case, in our opinion,
they are not so strong a piece of evidence
sufficient on its own and without anything
more to bring home the charges beyond
reasonable doubt.”
Therefore, in our view, the appellant’s guilt was not proved
beyond a reasonable doubt.”
16. Consequently, in our view, a report of a voluntary narco-analysis test
with adequate safeguards as well in place, or information found as a
result thereof, cannot form the sole basis of conviction of an accused
person. The second question is, therefore, answered in the negative.

5 2025 SCC Online SC 178.
6 2023 SCC OnLine SC 984.
[2025] 7 S.C.R. 403

Amlesh Kumar v. The State of Bihar

17. Adverting to the last question framed, the learned Amicus Curiae
has pointed out that there has been a divergence of views taken by
High Courts on the issue as to whether a narco-analysis test can
be claimed by an accused as a matter of right. Given the suspect
nature of a report of narco-analysis, the Amicus Curiae submitted
that this position must be clarified.
18. On the one hand, there is High Court of Judicature at Allahabad in
Rajesh Talwar v. CBI 7; High Court of Bombay in Dominic Luis v.
State8 and Mohd. Samir v. State9; High Court of Delhi in Ashwini
Kumar Upadhyay v. Union of India10; High Court of Kerala in Louis
v. State of Kerala11; High Court of Gujarat in State of Gujarat v.
Sanjay Kumar Kanchanlal Desai12 and High Court of Punjab &
Haryana in Navjeet Kaur v. State of Punjab13, have held that an
involuntary narco-analysis test cannot be relied on and have taken
an overall view of the circumstances when an accused has sought
a narco-analysis test himself.
19. On the other hand, there is Rajasthan High Court, which in Sunil
Bhatt v. State14, held that the accused can seek a narco-analysis
test at a relevant stage in view of the statutory right to lead evidence
in defence under Section 233 of the Criminal Procedure Code.
20. In our view, as rightly submitted by the learned Amicus, the above
view of the Rajasthan High Court cannot be sustained. It cannot be
said that undergoing a narco-analysis test is part of the indefeasible
right to lead evidence, given its suspect nature, and moreover, we
find the same to be in the teeth of the judgment of this Court in Selvi
(supra). It had been categorically observed:
“240. We must also contemplate situations where a threat
given by the investigators to conduct any of the impugned
tests could prompt a person to make incriminatory

7 2013 SCC Online All 5533.
8 2014 SCC Online Bom 452.
9 2017 SCC Online Bom 19.
10 2023 SCC Online Del 3816.
11 2021 SCC Online Ker 4519.
12 2014 SCC Online Guj 6150.
13 2015 SCC Online P&H 15351.
14 2022 SCC Online Raj 1443.
404 [2025] 7 S.C.R.

Supreme Court Reports

statements or to undergo some mental trauma. Especially
in cases of individuals from weaker sections of society
who are unaware of their fundamental rights and unable to
afford legal advice, the mere apprehension of undergoing
scientific tests that supposedly reveal the truth could push
them to make confessional statements. Hence, the act of
threatening to administer the impugned tests could also
elicit testimony. It is also quite conceivable that an individual
may give his/her consent to undergo the said tests on
account of threats, false promises or deception by the
investigators. For example, a person may be convinced
to give his/her consent after being promised that this
would lead to an early release from custody or dropping
of charges. However, after the administration of the tests,
the investigators may renege on such promises. In such
a case the relevant inquiry is not confined to the apparent
voluntariness of the act of undergoing the tests, but also
includes an examination of the totality of circumstances.
253. We are of the view that an untrammelled right of
resorting to the techniques in question will lead to an
unnecessary rise in the volume of frivolous litigation before
our courts.
264. In light of these conclusions, we hold that no individual
should be forcibly subjected to any of the techniques
in question, whether in the context of investigation in
criminal cases or otherwise. Doing so would amount to an
unwarranted intrusion into personal liberty. However, we do
leave room for the voluntary administration of the impugned
techniques in the context of criminal justice, provided that
certain safeguards are in place. Even when the subject
has given consent to undergo any of these tests, the test
results by themselves cannot be admitted as evidence
because the subject does not exercise conscious control
over the responses during the administration of the test.
However, any information or material that is subsequently
discovered with the help of voluntary administered test
results can be admitted in accordance with Section 27 of
the Evidence Act, 1872.”
(Emphasis supplied)
[2025] 7 S.C.R. 405

Amlesh Kumar v. The State of Bihar

21. In view of the above exposition in Selvi (Supra), the third question
is answered in the following terms :
The accused has a right to voluntarily undergo a narco-analysis test
at an appropriate stage. We deem it appropriate to add, that the
appropriate stage for such a test to be conducted is when the accused
is exercising his right to lead evidence in a trial. However, there is no
indefeasible right with the accused to undergo a narco-analysis test,
for upon receipt of such an application the concerned Court, must
consider the totality of circumstances surrounding the matter, such
as free consent, appropriate safeguards etc., authorizing a person
to undergo a voluntary narco-analysis test. We deem it appropriate
to reproduce and reiterate the guidelines issued in Selvi (Supra) in
this regard as follows :
“265. The National Human Rights Commission had
published Guidelines for the Administration of Polygraph
Test (Lie Detector Test) on an Accused in 2000. These
Guidelines should be strictly adhered to and similar
safeguards should be adopted for conducting the
“narcoanalysis technique” and the “Brain Electrical
Activation Profile” test. The text of these Guidelines has
been reproduced below:
(i) No lie detector tests should be administered except on
the basis of consent of the accused. An option should be
given to the accused whether he wishes to avail such test.
(ii) If the accused volunteers for a lie detector test, he
should be given access to a lawyer and the physical,
emotional and legal implication of such a test should be
explained to him by the police and his lawyer.
(iii) The consent should be recorded before a Judicial
Magistrate.
(iv) During the hearing before the Magistrate, the person
alleged to have agreed should be duly represented by a
lawyer.
(v) At the hearing, the person in question should also be
told in clear terms that the statement that is made shall
not be a “confessional” statement to the Magistrate but
will have the status of a statement made to the police.
406 [2025] 7 S.C.R.

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(vi) The Magistrate shall consider all factors relating to the
detention including the length of detention and the nature
of the interrogation.
(vii) The actual recording of the lie detector test shall be
done by an independent agency (such as a hospital) and
conducted in the presence of a lawyer.
(viii) A full medical and factual narration of the manner of
the information received must be taken on record.”
22. Before parting with this appeal, we place on record our appreciation
for the learned Amicus Curiae, Mr. Gaurav Agrawal, Senior Advocate,
in extending his invaluable assistance to the Court.
23. Keeping in view the above discussion, we have no doubt that the
impugned Order cannot be sustained. Consequently, the impugned
Order dated 9th November 2023 passed in Criminal Miscellaneous
No. 71293 of 2023 by the High Court of Judicature at Patna is
hereby set aside.
24. The bail application of the Appellant, pending if any, to be decided
in accordance with law.
25. In the attending facts and circumstances of this case, the Appeal
is allowed.
Pending application(s), if any, shall stand disposed of.

Result of the case: Appeal allowed.

†
Headnotes prepared by: Ankit Gyan